42 U.S.C. § 2000e

A Title VII claim against a business cannot proceed without evidence that the business qualifies as an employer under § 2000e(b).

Michaels v. Sassers Glass Works Inc. · filed 2023-03-20(b)

Because Michaels has presented no evidence for his view that Sasser’s Glass qualifies as an “employer” for purposes of Title VII and the FCRA, we GRANT the MSJ as to all claims arising under those two statutes (Counts III–X).

Section 2000e(b) requires a Title VII plaintiff to plead that the employer had at least fifteen employees.

Gordon v. APS Contractor Inc. · filed 2023-03-20(b)

An employer is not subject to the provisions of Title VII, unless the employer has at least fifteen employees. ... Here, plaintiffs fail to allege in the Complaint whether defendant APS satisfies this requirement. Because plaintiffs have failed to plead a required element of a Title VII discrimination claim, they are not entitled to default judgment on their Title VII claims.

Section 2000e(b) defines an employer to include a corporation with at least fifteen employees for each working day in twenty or more weeks of the current or preceding calendar year.

Rhoads v. Althom Inc. · filed 2023-03-20(b)

Under both statutes, an employer is defined, in relevant part, as a corporation “with fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year[.]” See 42 U.S.C. § 2000e(b); see id. § 12111(5). ... Based on Plaintiff’s allegations and her EEOC record, the Court concludes that Plaintiff has established, prima facie, the fifteen (15) employee requirement of Title VII/ADA.

Sufficient allegations that an integrated enterprise qualifies as an employer under § 2000e(b) allow a Title VII claim to survive dismissal.

Jackson v. Chick and Seafood Inc · filed 2023-04-04(b)

Accordingly, Jackson has alleged enough facts demonstrating CSI’s employer status to survive the motion to dismiss.

Section 2000e(b) defines an employer as a person engaged in an industry affecting commerce with fifteen or more employees for the specified period.

Mitchell v. Kenny/Wife · filed 2023-05-12(b)

First, “[t]he term ‘employer’ means a person engaged in an industry affecting commerce who has fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year[.]” 42 U.S.C. § 2000e(b). Plaintiff does not allege that Defendants’ business meets this criteria.

A county can qualify as an employer under § 2000e(b) when a reasonable jury could find that it employed the worker.

Milteer v. Navarro County Texas · filed 2023-05-19(b)

A reasonable jury could find that Navarro County was Milteer’s employer.

Section 2000e(b)’s fifteen-employee threshold can provide a meritorious defense to a Title VII claim when a company seeks to set aside a default judgment.

Rice v. HamiltonDavis Mental Health, Inc. · filed 2023-05-31(b)

Under this standard, HamiltonDavis has asserted meritorious defenses to the claims alleged against it, namely, that (1) it is not an “employer” under Title VII because it did not have the requisite number of employees during the relevant time period, see 42 U.S.C. § 2000e(b) (defining “employer” as “a person engaged in an industry affecting commerce who has fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year, and any agent of such a person....”); and (2) it had legitimate, nondiscriminatory reasons for plaintiff’s termination.

Municipal defendants are not employers subject to Title VII liability under § 2000e(b) absent an employment relationship.

JOHNSON v. THE CITY OF CLIFTON · filed 2023-06-29(b)

Therefore, there exists no genuine issue of material fact over whether the municipal Defendants were employers subject to Title VII liability.

A sole proprietor operating businesses under fictitious names may meet § 2000e(b)’s fifteen-employee threshold by counting employees across those businesses.

SPARKS v. SPEEDY KLEENE CAR WASH & LAUDROMAT · filed 2023-07-13(b)

There is no need to apply a single employer theory in this case because Speedy Kleene is not a legal entity separate from [Mr.] Devecka. The present case involves only one legal entity, [Mr.] Devecka, and a fictitious name under which he does business.

An allegation that the defendant employed more than fifteen people sufficiently pleads § 2000e(b)’s employee threshold at the motion-to-dismiss stage.

Carter v. Oasis Tropical Cafe, LLC · filed 2023-07-18(b)

For purposes of a motion to dismiss, the allegation that Defendants meet the employee-numerosity requirement is sufficient to establish that they are covered employers under Title VII and the FCRA.

An entity that does not control a worker’s terms and conditions of employment is not the worker’s employer under Title VII.

Singleton v. State of Louisiana · filed 2023-07-25(b)

In sum, the evidence shows that the Department (not the Commission) exercised exclusive control over the terms and conditions of Plaintiff’s employment with the State, and therefore the Department (not the Commission) was Plaintiff’s “employer” under Title VII and the FMLA.

A Title VII complaint must plausibly allege that the employer meets § 2000e(b)’s fifteen-employee threshold.

Sinclair v. The Ralph & Joan Forgione Estates · filed 2023-07-31(b)

Here, Plaintiff’s Title VII claim must be dismissed because he has failed to plead the required element that Defendants employed more than 15 employees.

A worker who was not an employee during the relevant period cannot count toward § 2000e(b)’s fifteen-employee threshold.

SMITH v. GEORGIA KIDNEY CONSULTANTS LLC · filed 2023-08-02(b)

Because Dr. Mackay was not an employee during the relevant period, GKC did not employ “fifteen or more employees for each working day in each of twenty or more calendar weeks” in 2020. 42 U.S.C. § 2000e(b). Therefore, GKC cannot be properly considered an employer and, consequently, cannot be liable under Title VII.

Title VII employer status requires sufficient control over the worker, especially hiring and firing authority.

Salatas v. Lake County Government · filed 2023-08-02(b)

in order to be considered an employer, a person or entity must exercise sufficient control over the alleged employee, with the most important consideration being whether the putative employer has hiring and firing power over the employee.

An entity’s right to control the worker’s work is the most important factor in determining Title VII joint employer status.

Ashley v. Morrison Management Specialists, Inc. · filed 2023-08-11(f)

The employer’s right to control the employee’s work is the most important factor in determining whether an employer-employee relationship exists.

Section 2000e(b)’s definition of employer does not make individual law firm partners or their P.C.s personally liable under Title VII.

Kovalenko v. Kirkland & Ellis LLP · filed 2023-08-23(b)

The Court finds that the law firm partners and their P.C.s are not “employers” under Title VII or FEHA.

Section 2000e(b)’s definition of employer does not permit a Title VII claim against a sheriff in his individual capacity.

Cordell v. West · filed 2023-08-24(b)

The Title VII, ADA, ADEA, and ACRA claims against Sheriff West are dismissed with prejudice because Sheriff West is not an “employer” capable of being sued in his individual capacity.

Section 2000e(b)’s definition of employer can cover joint or single employers, but issuing paychecks and appearing on a worker’s W-2 alone does not establish that status.

Curtis v. Summit County Children Services · filed 2023-08-28(b)

An “employer” is defined as “a person engaged in an industry affecting commerce who has fifteen or more employees . . . and any agent of such a person.” 42 U.S.C. § 2000e(b). ... Consistent with the analysis in Satterwhite, this Court finds an additional allegation that the Summit County Fiscal Officer issued Ms. Curtis’ paychecks and was listed as her employer on her W-2 would still be insufficient to establish – even at the pleading stage – that the County is an employer under the “joint-employer” or “single-employer” standards.

A parent company is not a joint employer under § 2000e(b) when the complaint alleges only general control of policies and no facts showing control over the same workers.

Casasola v. Control Systems International, Inc. · filed 2023-08-31(b)

The court concludes the first amended complaint fails to adequately allege facts showing that Defendant qualifies as Plaintiff’s employer for purposes of her Title VII claim.

Section 2000e(b) defines a Title VII employer as an entity with fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year.

MACK v. WATSON TRUCKING INC · filed 2023-09-13(b)

Title VII “limits the definition of ‘employer’ to entities that have ‘fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year.’”

Section 2000e(b) defines an employer as a person in an industry affecting commerce with at least fifteen employees during the specified period, including any agent of that person.

Tooke v. White · filed 2023-09-22(b)

Under Title VII an “employer” is “a person engaged in an industry affecting commerce who has fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year, and any agent of such a person.” 42 U.S.C. § 2000e(b).

Section 2000e defines an employer under Title VII to include a person engaged in an industry affecting commerce with fifteen or more employees and any agent of that person.

HERRING v. OCEAN COUNTY BOARD OF SOCIAL SERVICES · filed 2023-09-25(b)

The term “employer” as used in Title VII means “a person engaged in an industry affecting commerce who has fifteen or more employees... and any agent of such a person... .” 42 U.S.C. § 2000e(b). In considering the scope of covered employers, the Third Circuit has consistently concluded that individual supervisory employees are not subject to liability under Title VII.

Section 2000e(b) defines an employer for Title VII as a person engaged in commerce with at least fifteen employees during the specified period, including any agent of that person.

Foster v. DeWine · filed 2023-09-29(b)

For purposes of Title VII, an employer is “a person engaged in an industry affecting commerce who has fifteen or more employees for each working day in each twenty or more calendar weeks in the current or preceding calendar year, and any agent of such person ....” 42 U.S.C. § 2000e(b). An individual employee/supervisor who does not otherwise qualify as an “employer” may not be held liable under Title VII.

Section 2000e(b) requires evidence that the defendant was the plaintiff’s employer; working with the Center as a foster parent did not establish that relationship on this record.

Hawkins v. Counseling and Education Center Inc · filed 2023-10-17(b)

This record is too thin to support a reasonable fact finder in concluding that the Center was Hawkins’s employer within the meaning of Title VII.

Section 2000e(b) excludes an individual employee who has fewer than fifteen employees of his own from Title VII’s definition of “employer.”

Warner v. Hutson · filed 2023-10-18(b)

Title VII defines “employer” as an individual “engaged in an industry affecting commerce who has fifteen or more employees.” 42 U.S.C. § 2000e(b). Andrews is an employee of Defendant Hutson and does not have fifteen or more employees of his own.

A plaintiff must provide enough evidence of employee count to show the defendant qualifies as an employer under § 2000e(b).

Guzman-Perez v. Ojeda-Batista · filed 2023-11-09(b)

The Court therefore finds that Plaintiffs have failed to create a triable issue at this juncture regarding the number of employees required to satisfy the definition of “employer” under the ADEA and Title VII and they have therefore failed to satisfy their burden.

Section 2000e(b)'s fifteen-employee threshold cannot support summary judgment when the employee count remains genuinely disputed.

Yazzie v. National Organization for Women · filed 2024-01-22(b)

Given this uncertainty, the Court cannot grant summary judgment to NOW on the theory that it was not, at the relevant time, an employer under Title VII; simply put, although Yazzie carries the burden of proving that NOW was employer, NOW is the party that has access to the relevant evidence, and it has failed to carry its burden of showing there is no genuine issue of fact on the question.

Section 2000e(b) defines an employer by a fifteen-employee threshold measured over twenty or more calendar weeks in either the year of the alleged discrimination or the preceding calendar year.

Spears v. Nanaki L L C · filed 2024-01-24(b)

When applied to the definition of “employer,” the Court interprets the plain language of the statute to mean that an employer is one who employs fifteen or more employees for each working day in each of the twenty or more calendar weeks in the year in which the alleged discriminatory act occurred or alternatively, the proceeding calendar year.

Section 2000e(b)’s fifteen-employee minimum excludes board members who control the organization as employers rather than serve as its employees.

Fain v. Twin Lakes Regional Sewer District · filed 2024-01-22(b)

At least the first five factors set out in Clackamas indicate that the Trustees should be considered an employer instead of employees for purposes of Title VII. ... That qualifies them as employers, who do not count toward the 15-employee requirement of Title VII.

Section 2000e(b) excludes the United States and its wholly owned corporations from the definition of “employer.”

Neville v. Burrows · filed 2024-02-13(b)

And as a reflection of this statutory bifurcation, the term “employer,” as defined in § 701(b) of Title VII, 42 U.S.C. § 2000e(b), excludes the United States and its wholly owned corporations.

Section 2000e(b) requires an employer to have at least fifteen employees for each working day in at least twenty calendar weeks of the current or preceding calendar year.

Shaikh v. Aekta Motels LLC · filed 2024-02-27(b)

To be a Title VII “employer,” an entity must “ha[ve] fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or proceeding calendar year.” ... Thus, there is no genuine issue of material fact, and Plaintiff has failed to show Defendant was an “employer” for purposes of Title VII.

Section 2000e(b) does not require the twenty calendar weeks used to meet Title VII’s employer threshold to be consecutive.

Williams v. The Law Offices of Frederick K. Brewington · filed 2024-03-01(b)

Defendants’ interpretation of Section 2000e(b) is unpersuasive and, consequently, their charts are inaccurate. The plain text of Section 2000e(b) does not include the word “consecutive” when defining a Title VII employer as “a person engaged in an industry affecting commerce who has fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding year, and any agent of such person.” 42 U.S.C. § 2000e(b) (emphasis supplied).

Title VII’s definition of employer excludes supervisors and other employees sued in their individual capacities.

Omotoye v. Global Technical Talent · filed 2024-03-12(b)

Title VII permits suits against covered “employers,” a statutory term that excludes supervisors and other employees in their individual capacity.

Section 2000e(b)’s fifteen-employee threshold can be met during the calendar year of the alleged discrimination, even if the employer reaches fifteen employees only after the alleged act.

Rohrer v. Cooper Owens D.D.S., LLC · filed 2024-03-21(b)

By adopting the language it did, Congress plainly allows for Title VII liability w here a company grows to fifteen employees only after the offending act but still within same calendar year.

Section 2000e(b) defines an employer under Title VII to include a business employing at least 15 workers.

Portillo v. H Restaurant and Night Club, LLC · filed 2024-03-25(b)

And because Wheaton Lounge and El Tipico employed 15 or more servers during Portillo’s employment, see ECF No. 1 ¶ 29, they also qualify as “employers” under the federal, state, and local statutes. See 42 U.S.C. § 2000e(b); Md. Code Ann., State Gov’t § 20-601(d)(1)(i); Montgomery, Md. Code § 27-6.

Section 2000e(b) requires a Title VII employer to have at least fifteen employees for twenty or more weeks in the year of the alleged discrimination or the preceding year.

Migdon v. 171 Holdings · filed 2024-04-09(b)

Under Title VII, an employer must be “engaged in an industry affecting commerce who has fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year.” 42 U.S.C. § 2000e(b). For purposes of Title VII numerosity, ‘current calendar year’ means the year in which the alleged discrimination occurred, rather than the year of the district court judgment. See Vance v. Union Planters Corp., 209 F.3d 438, 446 (5th Cir. 2000). Here, 171 Junction Roadhouse did not open for business until October of 2015, leaving less than twenty weeks left in the year. Thus, the district court concluded that the twenty-week threshold could not have been met for that year. And there is no evidence in the record that suggests that employees were on the payroll in the preceding year, so the numerosity requirement could not have been met for the preceding calendar year either.

Section 2000e(b) defines an employer; deputies who were not the plaintiff’s employer could not be liable under Title VII.

Flores, Valerie v. Horn, Allen · filed 2024-04-10(b)

In any case, as Flores admits, the deputies were not her employer, so they could not be liable under Title VII.

Title VII requires at least 15 employees for an entity to qualify as an employer.

Webb, Katharine v. Playmonster LLC · filed 2024-04-18(b)

For Title VII, the minimum is 15 employees. 42 U.S.C. § 2000e(b). ... The court finds that Playmonster had at least 50 but no more than 100 employees in 2020 and 2021.

An entity with fewer than 15 employees does not qualify as an employer under § 2000e(b).

JOHNSON v. OMNI PROPERTY SERVICES MANAGEMENT, INC. · filed 2024-04-18(b)

Thus, the Court grants summary judgment and dismisses the Title VII claims where Omni did not employ 15 or more individuals.

Section 2000e(b) requires an employer to have at least fifteen employees and does not make supervisors personally liable unless they independently qualify as employers.

Butcher v. UCW-CWA Local 3865 (TV2) · filed 2024-05-30(b)

“Employer” is defined as “a person engaged in an industry affecting commerce who has fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year, and any agent of such person[.]” 42 U.S.C. § 2000e(b). ... Thus, to the extent plaintiff seeks to assert Title VII claims against Mr. Smyser and Mr. Smith in their individual capacities (or any other Jane or John Doe supervisors or employees of CWA or the Local), Sixth Circuit case law instructs that she cannot do so.

Section 2000e(b) defines an employer as a person engaged in an industry affecting commerce with at least 15 employees for the specified number of weeks.

Johlin-Thompson v. WSFX LLC · filed 2024-06-07(b)

Under Title VII, an employer means “a person engaged in an industry affecting commerce who has [15] or more employees for each working day in each of [20] or more calendar weeks in the current or preceding calendar year.” 42 U.S.C.S. § 2000e(b).

Section 2000e(b) requires an employer to have at least fifteen employees for a Title VII claim.

Heath v. Gallaway · filed 2024-06-10(b)

To proceed on a Title VII claim, Plaintiff must demonstrate that he was an employee of one of the organizations that he named as defendants and that the organization employs fifteen or more employees. See 42 U.S.C. § 2000e(b).

Section 2000e(b) requires an employer to have at least 15 employees for Title VII liability; another entity’s employees cannot be counted without evidence supporting their aggregation.

Padilla v. Midwest Health, Inc. · filed 2024-06-11(b)

Therefore, Defendant is entitled to judgment as a matter of law because it does not employ a sufficient number of employees to be subject to Title VII.

A third-party plan administrator is not an employer under Title VII merely because it administers an employee’s health benefits.

DOE v. CITY OF PHILADELPHIA · filed 2024-08-02(b)

Therefore, as alleged in her Second Amended Complaint, IBX cannot be considered Doe’s “employer” under Title VII.

Section 2000e’s definition of employer limits individual liability under Title VII to people who qualify as employers.

Olekanma v. Scruggs · filed 2024-08-05(b)

Title VII instructs that “a person cannot be held liable under Title VII in his or her individual capacity unless the person qualifies as an ‘employer’ within the meaning of the statute.” Hughley v. JetBlue Airways Corp., No. GLR-19-3523, 2020 WL 3451984, at *3 (D.Md. June 24, 2020).

A worker loaned to a government entity can qualify as its employee under Title VII when the alleged facts satisfy the hybrid economic realities and control test.

Privott v. City of New Orleans · filed 2024-08-12(b)

When looking past Plaintiff's misplaced legal conclusion of “joint” employment her complaint, Plaintiffs allegations satisfy the Hybrid Test for the purposes of this motion to dismiss.

Section 2000e(b) defines a Title VII employer as a person engaged in an industry affecting commerce with at least fifteen employees for the required twenty calendar weeks.

Eche v. UT Southwestern Health Systems · filed 2024-08-12(b)

An employer under Title VII is “a person engaged in an industry affecting commerce who has fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year.” 42 U.S.C.A. § 2000e. ... Therefore, UTSHS does not qualify as an “employer” under either Title VII or the ADEA.

Section 2000e(b) defines a Title VII employer as one with at least 15 employees on each working day for at least 20 weeks in the current or preceding year.

Porras v. IBX Construction · filed 2024-08-15(b)

The plaintiff also does not sufficiently allege that Bolex is an “employer” pursuant to Title VII because the allegations do not support an inference that the workers worked “each working day in each of twenty or more calendar weeks in the current or preceding year . . . .” 42 U.S.C. § 2000e(b).

Section 2000e(b) requires a plaintiff to allege facts supporting an inference that the defendant has enough qualifying employees to be covered.

Sun v. Wu · filed 2024-08-21(b)

In addition, although the case law is not definitive on this, it appears that a plaintiff in a Title VI and FEHA case must allege facts from which one could infer that the defendant has enough qualifying employees to be subject to either statute. 42 U.S.C. § 2000e(b); Cal. Gov. Code § 12926(d); see also Mousa v. Lauda Air Luftfahrt, A.G., 258 F. Supp. 2d 1329, 1335-37 (S.D. Fla. 2003); Eyeghe v. Thierry, 2014 WL 5242605, at *1 (S.D.N.Y. Oct. 15, 2014). Sun has failed to do that as well.

Section 2000e(b)’s definition of “employer” does not make individual supervisors liable under Title VII.

BROWN v. DEVEREUX · filed 2024-09-04(b)

An “employer” is defined as a “person engaged in an industry affecting commerce who has fifteen or more employees . . . and any agent of such a person.” 42 U.S.C. § 2000e(b). The United States Court of Appeals for the Third Circuit has declined to extend liability under Title VII to individuals, such as Sulli, holding the term “employer” as used in Title VII does not encompass individual employees. Sheridan v. E.I. DuPont de Nemours & Co., 100 F.3d 1061, 1078 (3d Cir.1996). Accordingly, any claims against Sulli are meritless and will be dismissed with prejudice.

Section 2000e(b) requires an employer to have at least 15 employees for each working day in 20 or more calendar weeks of the current or preceding year.

Bradley v. Tri-Lakes Casa, Inc. · filed 2024-09-30(b)

An employer is defined under Title VII as a “person engaged in an industry affecting commerce who has fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year.” 42 U.S.C. § 2000e(b). ... Tri-Lakes is not an employer for the purposes of Title VII.

Section 2000e(b) defines an employer covered by Title VII as one with at least fifteen employees for the required twenty calendar weeks.

Howard v. Run Hope Work Inc · filed 2024-11-19(b)

An “employer” under Title VII is defined as a person with “fifteen or more employees for each working day in each of twenty or more calendar weeks.” 42 U.S.C. § 2000e(b). ... Because Howard fails to allege the defendants had the requisite fifteen employees necessary to be subject to liability under Title VII, the Court will grant the defendants’ motion to dismiss Count I.

Section 2000e(b) defines an employer for Title VII; individual owners are not personally liable when the business is the employer.

GRAHAM v. CUCINA · filed 2024-12-12(b)

As a matter of law, the Court holds that Mr. and Mrs. Pasquarelli, as the owners of Abruzzi’s, cannot be held personally liable under Title VII.

Section 2000e(b)’s reference to an employer’s agents provides for employer liability; it does not make individual employees or supervisors personally liable under Title VII.

Cone v. Orrock · filed 2025-01-03(b)

Title VII defines “employer” as “a person engaged in an industry affecting commerce who has fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year, and any agent of such a person[.]” 42 U.S.C. § 2000e(b). The purpose of the agent provision is to incorporate respondeat superior liability into the statute. ... The United States Court of Appeals for the Eighth Circuit has consistently held that individual employees, including supervisors, may not be held liable under Title VII.

Section 2000e(b)’s definition of employer excludes a workplace with no authority over the employee.

Tunstall v. William E. Donaldson Correctional Facility · filed 2025-01-08(b)

Under Title VII, an employer is defined as “a person engaged in an industry affecting commerce who has fifteen or more employees . . . and any agent of such a person.” 42 U.S.C. § 2000e(b). ... The court finds that for purposes of any Title VII claim here, Plaintiff’s employer is either the ADOC or Commissioner Hamm. Donaldson cannot be Plaintiff’s employer because it has no authority over him as it is merely his workplace.

Section 2000e(b) includes states in Title VII’s definition of employer, abrogating their Eleventh Amendment immunity for Title VII claims.

Prince v. State of Michigan · filed 2025-01-28(b)

And it abrogated Eleventh Amendment immunity for Title VII claims when it included states in the statutory definition of “employer.”

Section 2000e(b) requires an employer to have at least 15 employees to be subject to Title VII.

Rhone v. Schmanke · filed 2025-03-07(b)

The minimum number of employees to be considered an “employer” under Title VII or the ADA is 15.

Section 2000e(b) defines an employer for Title VII purposes; individual employees who do not qualify as employers cannot be held personally liable under Title VII.

Sow v. Sysco Corp · filed 2025-03-31(b)

An “employer” under Title VII is “a person engaged in an industry affecting commerce who has fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year, and any agent of such a person . . .” 42 U.S.C. § 2000e(b). ... Having reviewed Plaintiff’s allegations, this Court finds that Plaintiff has failed to allege that they are within the definition of “employer” for purposes of this suit.

Section 2000e(b) requires at least fifteen employees or agents for at least twenty weeks in the current or preceding calendar year for an entity to qualify as a Title VII employer.

Burpo v. Fairfield Housing Authority · filed 2025-04-04(b)

Therefore, for Fairfield to qualify as a Title VII employer, Fairfield must have had at least fifteen employees or agents during at least twenty weeks of the year preceding or the year of Mr. Burpo’s termination. ... Therefore, as a matter of law, Fairfield Housing Authority does not constitute an employer for the purposes of Mr. Burpo’s Title VII claims.

Section 2000e(b) defines “employer” for Title VII; individual employees are not employers subject to Title VII liability.

BOOTH v. THE CITY OF PHILADELPHIA POLICE DEPARTMENT · filed 2025-04-07(b)

Finally, Booth’s Title VII retaliation claims against Defendant Drissel is dismissed with prejudice for the additional reason that Title VII only makes it unlawful for an “employer” to discriminate. 42 U.S.C. § 2000e-2(a)(1). An “employer” is defined as a “person engaged in an industry affecting commerce who has fifteen or more employees . . . and any agent of such a person.” 42 U.S.C. § 2000e(b). The United States Court of Appeals for the Third Circuit has declined to extend liability under Title VII to individuals, such as Defendant Drissel, holding the term “employer” as used in Title VII does not encompass individual employees.

Section 2000e(b) limits Title VII coverage to employers with at least fifteen employees for each working day in twenty or more calendar weeks of the current or preceding calendar year.

Kirby v. Gasaway Distributors Inc. · filed 2025-05-20(b)

As Gasaway correctly notes, Title VII only applies to employers who have “fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year.” See Walters v. Metro. Educ. Enters., Inc., 519 U.S. 202, 204 (1997) (quoting 42 U.S.C. § 2000e(b)). If Gasaway was not an “employer” for the purpose of Title VII, Kirby would have no Title VII claim.

Section 2000e(b) defines a covered employer; individual employees are not liable under Title VII.

Birchfield v. Compass Health Network · filed 2025-05-21(b)

Title VII defines “employer” as “a person engaged in an industry affecting commerce who has fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year.” 42 U.S.C. § 2000e(b). ... Because Title VII does not impose liability on individual employees, the Court dismisses her Title VII claims against the remaining defendants.

Section 2000e(b)’s definition of employer does not cover a defendant that was not the plaintiff’s employer.

Walker v. Saracen Casino Resort LLC · filed 2025-06-06(b)

these defendants are entitled to tribal sovereign immunity2 and were not Walker’s employer3 in any event.

Section 2000e(b) excludes the United States from the definition of “employer,” so the private-employer provision does not govern federal employees’ claims.

HILDEBRAND v. UNITED STATES DEPARTMENT OF DEFENSE · filed 2025-06-12(b)

So from the plain text, § 2000e-2(a)(1) applies to “employers,” and § 2000e(b) specifically excludes the federal government from the definition of “employer.”

Section 2000e(b) defines a Title VII employer as having at least fifteen employees for each working day in at least twenty weeks of the current or preceding calendar year.

Simpson v. Mark E Hall PC · filed 2025-09-03(b)

To be defined as an employer under Title VII, a defendant must have fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year. See 42 U.S.C. § 2000e(b).

Section 2000e(b)’s definition of “employer” does not encompass individual employees for Title VII liability.

Williams v. Remington Hospitality · filed 2025-10-14(b)

Courts have declined to extend liability under Title VII to individuals, such as Sheets and Rivera, holding the term “employer” as used in those statutes does not encompass individual employees. Sheridan v. E.I. DuPont de Nemours & Co., 100 F.3d 1061, 1078 (3d Cir.1996). Accordingly, the Title VII claims against Sheets and Rivera must be dismissed with prejudice.

Section 2000e(b) requires an employer to have at least fifteen employees.

Jenkins · filed 2025-10-16(b)

Because RCH has fewer than fifteen employees, under Title VII, RCH is not an employer.

Title VII defines an employer as a person or business with at least fifteen employees for each working day in twenty or more calendar weeks of the current or preceding year.

Sharp · filed 2025-10-16(b)

For discrimination and retaliation claims under Title VII, ADA, and MFEPA, “employer” is defined as a person or business that employs fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year. ... Therefore, the undisputed evidence establishes that AMDS Baltimore does not constitute an “employer” for the discrimination and retaliation claims under Title VII, ADA, or MFEPA.

Section 2000e(b) defines an employer; individual coworkers and supervisors are not employers subject to Title VII liability.

D'ANGELO · filed 2025-11-21(b)

D’Angelo may not, therefore, assert claims under Title VII against individuals who are not his employer, including any coworkers or supervisors. An “employer” is defined as a “person engaged in an industry affecting commerce who has fifteen or more employees . . . and any agent of such a person.” 42 U.S.C. § 2000e(b).

Section 2000e’s definition of employer does not include supervisors sued in their individual capacity under Title VII.

Uribe · filed 2025-12-17(b)

Because the Court agrees with the parties that “[s]upervisors do not qualify as employers under Title VII,” Munoz’s Motion to Dismiss is granted as to Count III.

Section 2000e(b)’s employee threshold is an element of a Title VII claim, not a jurisdictional prerequisite.

Rhone v. Schmanke · filed 2026-01-12(b)

We cannot affirm on this ground because in Arbaugh v. Y&H Corp., 546 U.S. 500, 516 (2006), the Supreme Court held the employee Title VII numerosity requirement is an element of the claim and not a jurisdictional prerequisite.

Section 2000e(b) includes an employer’s agent in its definition of employer; a person with no alleged agency relationship does not qualify on that basis.

ZARROW · filed 2026-02-03(b)

Zarrow cannot assert a Title VII claim against Henwood, as Title VII makes it unlawful for an “employer” to discriminate. ... There is no suggestion in the Complaint that Henwood, apparently a resident of Inglis House, was acting as its agent.

Section 2000e(b) includes an employer’s agents in its definition of “employer,” but an individual sued in an official capacity must exercise control over hiring to qualify as an agent for a Title VII claim.

Poston · filed 2026-03-30(b)

Even if the Court presumed Poston intended to sue Neill and Jackson in their official capacities based on the inclusion of their titles in her listing of them as defendants,12 she does not allege they exercised control over hiring such that they could be considered agents of Carroll County for purposes of her Title VII claims. Consequently, the Title VII claims against Neill and Jackson will be dismissed for failure to state a claim.

Section 2000e(b) requires a Title VII defendant to qualify as an employer; being an employee of the plaintiff’s employer does not create individual liability.

Venerable · filed 2026-06-02(b)

It does not allege facts showing that any of the Individual Defendants satisfy the requirements under either Title VII or the ADEA to be considered Plaintiff’s employer. And because neither statute permits individual liability, Plaintiff cannot state a claim against the Individual Defendants based solely on their status as USD 500 employees.

Section 2000e(b) defines which employers are covered by Title VII.

Rogillio v. Diamond Shamrock Chemical Co. · filed 1977-12-31(b)

During the relevant time, Diamond Shamrock was an “employer” as that term is defined in Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq.

A corporation can qualify as an employer under Title VII’s definition in § 2000e(b).

Harper v. General Grocer Co. · filed 1978-03-31(b)

Defendant, General Grocer Company, a corporation duly organized and existing under the laws of the State of Missouri, is an employer within the meaning of 42 U.S.C. § 2000e et seq.

Section 2000e defines a corporation operating an elevator construction and service business as a person and employer in an industry affecting commerce.

Randolph v. United States Elevator Corp. · filed 1978-04-14(a), (b), (g), (h)

At all times material hereto, U.S. Elevator was a person and employer in an industry affecting commerce as defined in Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e(a), (b), (g) and (h).

Section 2000e(b) defines which entities qualify as employers under Title VII.

Rivers v. Westinghouse Electric Corp. · filed 1978-04-21(b)

Defendant Westinghouse Electric Corporation is an “employer”, within the meaning of Title VII of the Civil Rights Act of 1964, as amended.

Section 2000e(b) defines who qualifies as an employer under Title VII.

Lee v. City of Richmond · filed 1978-07-26(b)

Defendant City of Richmond (hereinafter City) is an employer within the meaning of Title VII, 42 U.S.C. § 2000e(b).

A telephone equipment manufacturer may qualify as an employer under § 2000e(b).

Kyriazi v. Western Electric Co. · filed 1978-10-30(b)

Defendant Western, an “employer” within the meaning of 42 U.S.C. § 2000e(b), is engaged in the manufacture of telephone equipment.

A corporation engaged in interstate commercial hauling can qualify as an employer under Title VII.

Lumas v. Commercial Cartage Co. · filed 1978-10-31(b)

Defendant is an employer within the meaning of 42 U.S.C. § 2000e et seq.

Section 2000e defines which entities qualify as employers under Title VII, including covered colleges.

Kunda v. Muhlenberg College · filed 1978-11-17(b)

Defendant Muhlenberg College is an “employer” within the meaning of that term as defined in 42 U.S.C. §§ 2000e and 2000e-l (Supp. V).

Section 2000e's employer definition covers a company engaged in interstate commerce that continuously employs more than twenty-five people.

Equal Employment Opportunity Commission v. Fry-Wagner Moving & Storage Co. · filed 1979-02-27(b)

Said defendant does business within the state of Missouri, engaging in the moving and storage of furniture and other items in interstate commerce. Said defendant has continuously employed more than twenty-five employees and is an employer within the meaning of 42 U.S.C. § 2000e et seq.

Section 2000e(b) defines an employer by its involvement in an industry affecting commerce and its employee count.

Morales v. Dain, Kalman & Quail, Inc. · filed 1979-03-29(b)

Defendant Dain, Kalman & Quail, Inc., during the applicable period from 1968 to the beginning of 1976, was engaged in an industry affecting commerce and had 25 or more employees, thus being an employer under 42 U.S.C. § 2000e(b).

Section 2000e(b) originally excluded state and local governments from the definition of “employer,” but the 1972 amendment included them.

Hansbury v. Regents of University · filed 1979-04-18(b)

Section 701(b) of the Civil Rights Act of 1964, 42 U.S.C. § 2000e(b) was amended by Pub.L. No. 92-261, § 2(2), 86 Stat. 103 (1972), to include state and local governments within the definition of “employer.” As originally enacted, the section excluded these entities from coverage.

Section 2000e(b) covers an employer engaged in an industry affecting commerce that employs at least 15 people.

Harris v. Ralston Purina Co. · filed 1979-06-06(b)

Defendant is an employer within the meaning of 42 U.S.C. §§ 200,Oe, 2000e(b), (g), and (h), in that defendant is engaged in an industry affecting commerce and employs at least 15 persons.

Section 2000e(b)’s definition of employer includes supervisory employees as agents for claims based on their alleged harassment; a discharge claim against them must allege that they participated in the firing decision.

Obradovich v. Federal Reserve Bank of New York · filed 1983-08-30(b)

The statute does not define “agent”; however, courts have interpreted the term to include supervisory employees and employees who “participated in the decision making process that forms the basis of the alleged discrimination.” ... Those allegations adequately state a claim against Jaus and Eckhoff for the alleged harassment based on discriminatory conduct.

Section 2000e(b) defines which employers are covered by Title VII.

Hagans v. Budd Co. · filed 1984-09-29(b)

2. Budd is an employer within the meaning of 42 U.S.C. § 2000e(b) and 29 U.S.C. § 185(b).

Section 2000e(b) defines who qualifies as an employer under Title VII.

Buskus v. Southwestern Bell Yellow Pages, Inc. · filed 1990-09-13(b)

The defendant is an employer within the meaning of 42 U.S.C. § 2000e et seq.

Section 2000e(b) includes an employer’s agents, including supervisors who exercise significant control over hiring, firing, or employment conditions.

Tom PIERCE, Plaintiff-Appellant, v. COMMONWEALTH LIFE INSURANCE COMPANY and Capital Holding Corporation, Defendants-Appe · filed 1994-11-29(b)

Under Title VII, an “employer” is defined as “a person engaged in an industry affecting commerce ..., and any agent of such person.” 42 U.S.C. § 2000e(b) (emphasis added); see also K.R.S. § 344.040(1). The term “agent” is not defined by Title VII, but has been interpreted by courts as an individual who “serves in a supervisory position and exercises significant control over the plaintiffs hiring, firing or conditions of employment.”

Section 2000e’s definition of employer includes WMATA.

Jones v. Washington Metropolitan Area Transit Authority · filed 1996-10-15(b)

WMATA is an employer as defined by Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. §§ 2000e et seq.

Section 2000e(b) defines a Title VII employer as one with at least fifteen employees for each working day in twenty or more weeks of the current or preceding calendar year.

Hoar v. Prescott Park Arts Festival, Inc. · filed 1997-08-25(b)

In pertinent part, Title VII defines “employer” as one “who has fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year.” 42 U.S.C.A. § 2000e(b). ... On the record presented, then, plaintiff has carried his burden of showing subject matter jurisdiction at least sufficiently to avoid dismissal at this point.

Section 2000e(b)'s definition of employer does not make supervisors personally liable for plainly delegable personnel decisions such as promotion and discharge.

Chung v. BNR, Inc./Northern Telecom, Inc. · filed 1997-10-20(b)

Title VII defines “employer” as a “person engaged in an industry affecting commerce who has fifteen or more employees ... and any agent of such person....” 42 U.S.C. § 2000e(b). ... Applying the ease law recited above, Bundy and Conley are not “employers” within the meaning of Title VII. Defendants’ motion to dismiss plaintiffs second claim for relief against Bundy and Conley will be allowed.

Section 2000e(b) defines a Title VII employer as a person engaged in an industry affecting commerce with fifteen or more employees.

Walker v. Boys and Girls Club of America · filed 1999-03-19(b)

A plaintiff may bring a Title VII action against any “employer,” defined as “a person engaged in an industry affecting commerce who has fifteen or more employees ...” 42 U.S.C. § 2000e(b). The relevant portion of the definition of “employer” in the ADA is identical to the definition in section 2000e(b) of Title VII. 42 U.S.C. § 12111(5)(A). If the Plaintiff cannot establish that the Defendants meet the statutory definition of “employer,” this court lacks jurisdiction to hear the plaintiffs Title VII and ADA claims.

Section 2000e(b)'s definition of “employer” applied to LSI until the corporation dissolved.

Rowry v. Litigation Solutions, Inc. · filed 2000-02-08(b)

It is undisputed that, until the corporation dissolved, LSI was an “employer” as defined in Section 701(b) of Title VII, 42 U.S.C. § 2000e(b).

Section 2000e(b) defines “employer” for Title VII and does not make individual employees liable as employers.

JOHNSON v. CHILDREN'S HOSPITAL OF PHILADELPHIA · filed 2021-10-21(b)

An “employer” is defined as a “person engaged in an industry affecting commerce who has fifteen or more employees . . . and any agent of such a person.” 42 U.S.C. § 2000e(b). The Third Circuit has declined to extend liability under Title VII to individuals, holding the term “employer” as used in Title VII does not include individual employees. Sheridan v. E.I. DuPont de Nemours & Co., 100 F.3d 1061, 1078 (3d Cir. 1996). Accordingly, we shall dismiss Johnson’s claims against Lipinski, Johnson, McFadden, Riley, Jackson, Lourie, Dinsinick, and Crowe because they are not subject to liability under Title VII.

Section 2000e(b) includes an employer’s agents to allow employer liability for their acts, but does not make the agents personally liable under Title VII.

Carranza v. Shelton & Valadez, P.C. · filed 2022-06-17(b)

Although Title VII expressly references employers’ agents, the Fifth Circuit has held that the statute does not impose individual liability.

Section 2000e(b) excludes the United States from Title VII’s definition of “employer,” although Title VII’s retaliation prohibition still applies to federal employers.

Jeffries v. Lynch · filed 2022-07-27(b)

Although the text of Title VII prohibition on retaliation uses the term “employer,” 42 U.S.C. § 2000e-3(a), which is elsewhere defined to expressly exclude “the United States,” 42 U.S.C. § 2000e(b), courts including the D.C. Circuit regularly hold that the provisions of § 2000e-3(a) also apply to federal employers.

Section 2000e(b) excludes the United States from Title VII’s definition of “employer.”

Muldrow v. Garland · filed 2022-08-29(b)

Yet Title VII’s definition of “employer” explicitly says that the term “does not include the United States.” 42 U.S.C. § 2000e(b).

Section 2000e(b)’s definition of employer does not make an individual officer or employee personally liable under Title VII solely because they act for an employer.

Brown v. Talavera · filed 2025-10-10(b)

Fifth Circuit law is clear that individuals who serve as officers or employees of an employer are not Title VII employers as necessary to be named as Title VII defendant.

Section 2000e(b) defines a Title VII employer to include a person engaged in an industry affecting commerce with at least fifteen employees.

Brown v. Bratton · filed 2020-02-21(b)

The County is a proper defendant with respect to plaintiff’s claims under 42 U.S.C. §§ 1981 and 1983 and Title VII. See 42 U.S.C. § 2000e(b) (defining an “employer” to include “a person engaged in an industry affecting commerce who has fifteen or more employees”); Monell v. Dep’t of Soc. Servs., 436 U.S. 658, 691 (1978) (holding that municipal entities may be held liable under § 1983); accord Fountain v. Anne Arundel Cty. Gov’t, RBD-05-2494, 2007 WL 2413069 (D. Md. Aug. 21, 2007) (assessing the plaintiff’s § 1981 and Title VII claims against a county employer).

Section 2000e(b) covers employers with at least fifteen employees on each working day for twenty or more calendar weeks in the year of the alleged discrimination or the preceding year.

Sanford v. Main Street Baptist Church Manor · filed 2011-12-05(b)

Employers are subject to Title VII only if they have at least fifteen employees on each working day for twenty or more calendar weeks in either the year in which the alleged discrimination occurred or the preceding year.

Section 2000e’s definition of a labor organization is not a jurisdictional prerequisite to a Title VII claim.

Watford v. Jefferson County Public Schools · filed 2017-09-01(d)

However, the “labor organization” designation is located in the definitions section of the ADEA and Title VII, a “provision that ‘does not speak in jurisdictional terms or refer in any way to the jurisdiction of the district courts.’” See Arbaugh v. Y & H Corp., 546 U.S. 500, 515–16 (2006) (quoting Zipes v. Trans World Airlines, Inc., 455 U.S. 385, 394 ... (1982)), discussed in Cobb v. Contract Transp., Inc., 452 F.3d 543, 549–50 (6th Cir. 2006). It is therefore not a jurisdictional prerequisite.

Section 2000e(e)(4) covers a local union chartered by an international union that meets the commerce requirement when local members also enjoy membership in the international union.

Rainey v. Town of Warren · filed 2000-01-10(e)(4)

Thus, under § 701(e)(4), the Local Union qualifies as a “labor organization” engaged in an industry affecting commerce.

A police officers association can qualify as a labor organization subject to Title VII under § 2000e(d) and (e).

DeAngelis v. El Paso Municipal Police Officers Ass'n · filed 1995-05-11(d), (e)

We reject the Association's assertion that it is not a labor organization subject to Title VII. 42 U.S.C. § 2000e(d)(e).

Section 2000e(d) and (e) define a labor organization engaged in an industry affecting commerce to include a union like Local 212.

Dobbins v. Local 212, International Brotherhood of Electrical Workers · filed 1968-10-10(d), (e)

5. The defendant U is a labor organization engaged in an industry affecting commerce, as those terms are defined in 42 U.S.C. § 2000e(d and e).

Section 2000e(d) covers a union that represents workers in dealings with employers over employment terms and conditions.

Vogler v. McCarty, Inc. · filed 1968-01-31(d)

The defendant Local 53 is a labor organization within the meaning of 42 U.S.C. § 2000e-(d) which represents workmen engaged in the asbestos and insulation trade in the Southeastern portion of Louisiana, including the metropolitan areas of New Orleans and Baton Rouge, and some counties in the State of Mississippi. It exists for the purpose of dealing with employers on behalf of employees concerning terms and conditions of employment, including grievances, labor disputes, wages and hours of work.

Section 2000e(d) defines a labor organization to include its agents, making their activities subject to Title VII.

Butler v. Local No. 4 & Local No. 269, Laborers' International Union of North America · filed 1969-10-09(d)

This Court does not agree. Defining a labor organization to include its agents delineates the scope of application of the sections of Title VII prohibiting unlawful employment practices. It does not suggest that the term “respondent” as used in 42 U.S.C. § 2000e-5(e) has the same meaning. According to the definition, the activities of agents of labor organizations are subject to the provisions of Title VII. However, the charging of one before EEOC does not make a respondent of the other.

Section 2000e(d) includes agents within the definition of a labor organization, making their activities subject to Title VII.

McDonald v. American Fed. of Musicians of US and Can. · filed 1970-01-13(d)

Defining a labor organization to include its agents [42 U.S.C. § 2000e(d)] delineates the scope of application of the sections of Title VII prohibiting unlawful employment practices. It does not suggest that the term “respondent” as used in 42 U.S.C. § 2000e-5(e) has the same meaning. According to the definition, the activities of agents of labor organizations are subject to the provisions of Title VII. However, the charging of one before the EEOC does not make a respondent of the other. Butler v. Local No. 4, supra.

Section 2000e(d) and (e) define a labor organization and an industry affecting commerce for Title VII purposes.

United States v. United Ass'n of Journeymen & Apprentices of the Plumbing & Pipe Fitting Industry of the United States & · filed 1969-08-15(d), (e)

Local 73 is a labor organization engaged in an industry affecting commerce within the meaning of 42 U.S.C. § 2000e(d), (e).

Section 2000e(d) defines a labor organization, and section 2000e(e) defines industry affecting commerce.

Hicks v. Crown Zellerbach Corporation · filed 1970-02-25(d), (e)

The International is a labor organization engaged in industry affecting commerce, within the meaning of Sec. 701(d), (e) of the Civil Rights Act of 1964, 42 U.S.C. Sec. 2000e(d), (e).

Section 2000e defines labor organizations and industries affecting commerce for purposes of Title VII.

United States v. LOCAL NO. 8, INT. ASS'N OF BRIDGE, S., O. & RI · filed 1970-06-16(d), (e)

Local 86 is a labor organization within the meaning of 42 U.S.C. § 2000e (d) and is engaged in an industry affecting commerce within the meaning of 42 U.S.C. § 2000e(e).

Section 2000e(d) and (e) cover unions and their locals that represent employees in an industry affecting commerce.

Long v. Georgia Kraft Company · filed 1971-01-08(d), (e)

The United Papermakers and Paper Workers, AFL-CIO, its Local 654, and the International Brotherhood of Pulp, Sulphite and Paper Mill Workers and its two Locals 804 and 805 are labor organizations engaged in an industry affecting commerce within the meaning of Sec. 701(d) (e) of the Civil Rights Act of 1964, 42 U.S.C.A. § 2000e(d) (e).

Section 2000e(d) covers the defendant longshoremen’s unions as labor organizations, and § 2000e(e) covers the industry in which they work as an industry affecting commerce.

United States v. International Longshoremen's Ass'n · filed 1971-11-12(d), (e)

The Defendants included the International Longshoremen’s Association (hereinafter called the I.L.A.), the South Atlantic and Gulf Coast District of the I.L.A. (hereinafter referred to as District), and thirty-seven local general cargo longshoremen’s unions chartered by the I.L.A., all of whom are labor organizations within the meaning of 42 U.S.C. § 2000e(d), and all of whom are engaged in an industry affecting commerce within the meaning of 42 U.S.C. § 2000e(e).

Section 2000e defines a labor organization and an industry affecting commerce; a union may fall within both definitions.

United States v. Local 638 · filed 1972-01-03(d), (e)

Local 638 is a labor organization within the meaning of 42 U.S.C. § 2000e (d) and is engaged in an industry affecting commerce within the meaning of 42 U.S.C. § 2000e(e).

Section 2000e covers a union as a labor organization when it maintains a hiring hall and operates in an industry affecting commerce.

United States v. Local 638, Enterprise Ass'n of Steam · filed 1972-07-07(d), (e)

1. Local 40 is a labor organization within the meaning of 42 U.S.C. § 2000e(d) and is engaged in an industry affecting commerce within the meaning of 42 U.S.C. § 2000e(e).

Section 2000e covers labor unions engaged in an industry affecting commerce as labor organizations under Title VII.

Stevenson v. INTERNATIONAL PAPER COMPANY, MOBILE, ALA. · filed 1972-12-07(d), (e)

The defendant labor unions are organizations engaged in an industry affecting commerce within the meaning of Section 701(d) (e) of the Civil Rights Act of 1964, 42 U.S.C., Section 2000e(d)(e).

Sections 2000e(d) and (e) cover an electricians’ union with approximately 600 journeyman members as a labor organization engaged in an industry affecting commerce.

United States v. United Ass'n of Journeymen & Apprentices of the Plumbing & Pipefitting Industry of the United States & · filed 1973-08-20(d), (e)

Local 52 has approximately 600 journeyman members and is a labor organization engaged in an industry affecting commerce within the meaning of Section 701(d), (e), of Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e(d), (e).

Section 2000e’s definitions cover qualifying local, regional, and international unions as labor organizations under Title VII.

Sagers v. Yellow Freight System, Inc. · filed 1973-09-27(d) and (e)(3)

The Unions and Local 728 are labor unions covered by Title VII of the Act. See § 701(d) and (e)(3) of the Act, 42 U.S.C. § 2000e(d) and (e)(3).

Section 2000e’s definition of a labor organization does not give a collective bargaining representative a special role in Title VII actions against an employer.

Stewards v. American Airlines, Inc. · filed 1973-12-21(d)

Surely the fact that a labor organization is defined in 42 U.S.C. § 2000e and made a potential defendant in unlawful employment practice cases does not, as counsel seems to suggest, indicate an intention on the part of Congress that a collective bargaining representative play a special role in Title VII actions to redress unlawful employment practices by an employer.

Section 2000e(e) includes a certified union acting as employees’ exclusive bargaining representative within the definition of a labor organization.

Tuma v. American Can Company · filed 1974-02-28(e)

It is a labor organization within the meaning of § 701(d) and (e) of Title VII [42 U.S.C. § 2000e(d) and (e)] and within the meaning of § 2(5) [29 U.S.C. § 152(5)] of the National Labor Relations Act.

Section 2000e(d)'s definition of a labor organization covers the defendant unions.

Myers v. Gilman Paper Corporation · filed 1975-01-14(d)

2. Defendant Unions are labor organizations within the meaning of Section 701(d) of the Civil Rights Act of 1964, 42 U.S.C. § 2000e(d).

Section 2000e defines Stockham as an employer and the named unions as labor organizations for Title VII purposes.

James v. STOCKHAM VALVES AND FITTINGS COMPANY · filed 1975-03-19(b), (d)

The defendant Stockham is a Delaware corporation doing business in the State of Alabama and in the Southern Division of the Northern District of Alabama, and is an “employer” within the meaning of 42 U.S.C. § 2000e(b). ... Both of these defendants are “labor organizations” within the meaning of 42 U.S.C. § 2000e(d).

Section 2000e(e) requires a local labor organization that does not operate a hiring hall or hiring office to meet the minimum membership requirement for Title VII coverage.

Local No. 293 of the International Alliance of Theatrical Stage Employees v. Local No. 293-A of the International Allian · filed 1976-01-23(e)

Absent such an allegation, Local 293 must show that the membership of Local 293 — A satisfies the minimum membership requirement of the Act.

Section 2000e(d)'s definition of a labor organization includes Local 5.

United States v. International Union of Elevator Constructors, Local Union No. 5 · filed 1976-07-21(d)

Local 5 is a labor organization within the meaning of Title VII. 42 U.S.C. § 2000e(d).

Section 2000e(d) includes Local 5 within Title VII’s definition of a labor organization.

United States v. International Union of Elevator Constructors · filed 1976-07-21(d)

Local 5 is a labor organization within the meaning of Title VII. 42 U.S.C. § 2000e(d).

Section 2000e(d) covers an ironworkers' union as a labor organization.

Rule v. International Ass'n of Bridge, Structural & Ornamental Ironworkers, Local Union No. 396 · filed 1976-10-06(d)

22. Local 396 is a labor organization within the meaning of 42 U.S.C. § 2000e(d), and its principal place of business is 2500 59th Street, St. Louis, Missouri.

Section 2000e(d)'s definition of labor organization covers Local 396, an ironworkers' union.

Rule v. INTERN. ASS'N OF BRIDGE, STRUCT. & ORN. IRONWKRS. · filed 1976-10-06(d)

22. Local 396 is a labor organization within the meaning of 42 U.S.C. § 2000e(d), and its principal place of business is 2500 59th Street, St. Louis, Missouri.

Section 2000e(d) requires a labor organization to deal with a statutory employer; a union does not qualify with respect to its dealings with an entity that employs only one person.

Renfro v. Office & Professional Employers International Union, Local 277 · filed 1977-01-17(d)

For Local 277 to be a statutory “labor organization” it must deal with a statutory “employer”. It is clear Local 277 does not meet this requirement and this Court must conclude that Local 277 is not a “labor organization” under the statute with respect to its dealings with the Council.

Section 2000e(d) requires a union to deal with a statutory employer to qualify as a labor organization with respect to those dealings.

Rose RENFRO v. OFFICE AND PROFESSIONAL EMPLOYERS INTERNATIONAL UNION · filed 1977-02-28(d)

For Local 277 to be a statutory "labor organization" it must deal with a statutory "employer". It is clear Local 277 does not meet this requirement and this Court must conclude that Local 277 is not a "labor organization" under the statute with respect to its dealings with the Council.

Section 2000e(d) and (e) define the labor organizations and commerce covered by Title VII.

Stevenson v. International Paper Co. · filed 1977-04-29(d), (e)

3. Defendants United Paperworkers International Union and its Local 582 are labor organizations in an industry affecting commerce within the meaning of Title VII of the Civil Rights Act of 1964. 42 U.S.C. § 2000e(d), (e).

Section 2000e(b) covers National Airlines as an employer, and subsection (c) covers ALPA and TWU as labor organizations.

Gardner v. National Airlines, Inc. · filed 1977-05-17(b), (c)

It is undisputed that defendant National Airlines, Inc. is an “employer” as defined in 42 U.S.C. § 2000e(b), and that ALPA and TWU are “labor organizations” within the meaning of 42 U.S.C. § 2000e(c).

A police employees’ collective bargaining agent can be a labor organization under § 2000e(d) and operate in a business affecting commerce under § 2000e(e).

United States v. City of Buffalo · filed 1978-08-01(d), (e)

It is a labor organization under 42 U.S.C. § 2000e(d) and in a business which affects commerce under 42 U.S.C. § 2000e(e).

Section 2000e defines which entities qualify as employers and labor organizations under Title VII.

Kellin v. ACF Industries · filed 1978-10-13

Defendant ACF is an employer, and the Union is a labor union within the meaning of 42 U.S.C. § 2000e et seq.

Section 2000e(d) includes a union representing brickmasons and apprentices within Title VII’s definition of a labor organization.

Patterson v. Youngstown Sheet and Tube Co. · filed 1979-07-17(d)

Defendant Local 6 is a labor organization within the meaning of Title VII, 42 U.S.C. § 2000e(d), and Plaintiffs have met the jurisdictional prerequisites to suit against Local 6 under Title VII.

Section 2000e(d) covers a sheet metal workers union engaged in an industry affecting commerce as a labor organization.

Reynolds v. Sheet Metal Workers Local 102 · filed 1980-04-08(d)

1. Defendant Sheet Metal Workers Local 102 (“Local 102”) is a union and labor organization within the meaning of § 701(d), Title VII of the 1964 Civil Rights Act, 42 U.S.C. § 2000e(d)(1976), and is engaged in an industry affecting commerce.

A labor organization cannot be deemed engaged in an industry affecting commerce merely because it represents employees of a state governmental entity.

Equal Employment Opportunity Commission v. California Teachers Ass'n · filed 1982-01-21(e)(2)-(4), (h)

Accordingly, we hold that CTA cannot be deemed to be engaged in an industry affecting commerce and thus subject to Title VII merely by virtue of the fact that it represents employees of a state governmental entity.

Section 2000e's definition of a labor organization covers a union representing employees in truckdriver and warehouseman jobs.

EEOC v. Safeway Stores, Inc. · filed 1982-03-31(d)

The Union is a labor organization as defined in Title VII of the Civil Rights Act of 1964, as amended, and in the Labor-Management Relations Act of 1947, 29 U.S.C. § 152(5).

Section 2000e(b) and (d) include agents in the definitions of employers and labor organizations, allowing an agency relationship with a joint apprenticeship committee to support a Title VII suit against those entities.

Equal Employment Opportunity Commission v. Charleston Electrical Joint Apprenticeship Training Committee · filed 1984-07-16(b), (d)

The definitions section of Title VII defines labor organizations and employers as including agents of such entities. 42 U.S.C. § 2000e(b) & (d). ... Given the application of agency concepts in Title VII actions, this Court finds that the Plaintiff has raised a genuine issue of material fact as to whether the Charleston Electrical Joint Apprenticeship Training Committee was the agent of Local 466 and NECA.

Section 2000e(e) covers a labor organization engaged in an industry affecting commerce.

Equal Employment Opportunity Commission v. Local 798 of the United Ass'n of Journeymen · filed 1986-09-05(e)

3. Local 798 is a labor organization engaged in an industry affecting commerce within the meaning of Title VII, 42 U.S.C. § 2000e(d) and (e).

Section 2000e(d) and (e) define which entities qualify as labor organizations under Title VII.

Alexander v. Local 496, Laborers International Union of North America · filed 1991-12-10(d), (e)

Local 496 and the International Union are labor organizations as defined in 42 U.S.C. § 2000e(d), (e).

Section 2000e(d) defines a labor organization for Title VII purposes.

Myree v. Local 41, International Brotherhood of Electrical Workers · filed 1992-03-06(d)

Local 41 is a labor organization as defined in 42 U.S.C. § 2000e(d).

Section 2000e(e) limits Title VII coverage of labor organizations to those with a qualifying hiring hall or sufficient membership representing employees in an industry affecting commerce.

Saini v. Bloomsburg University Faculty · filed 1993-06-30(e)

With exceptions which do not apply here, only those organizations which either 1) maintain or operate a hiring hall or a hiring office which procures employees or employment opportunities, or 2) have fifteen or more members and represent employees of an employer which is engaged in an industry affecting commerce fall into that category. 42 U.S.C. § 2000e(e). ... In this case, there is no allegation, and no proof, that BUFA maintains or operates a hiring hall or hiring office. Nor is there any allegation, or any proof, that BUFA members, who are faculty members of Pennsylvania state-owned universities, are engaged in an industry which affects interstate commerce. Plaintiffs Title VII claim is dismissable on that basis alone.

Section 2000e(d) defines a labor organization and section 2000e(e) describes when it is engaged in an industry affecting commerce.

Catley v. Graphic Communications International, Union Local 277-M · filed 1997-10-23(d), (e)

The term “labor organization” is defined in 42 U.S.C. § 2000e(d) as a labor organization engaged in an industry affecting commerce and any agent of such organization. The conditions under which a labor organization shall be deemed to be engaged in an industry affecting commerce is further described in 42 U.S.C. § 2000e(e).

Section 2000e excludes unions representing federal employees against federal employers from its definition of labor organizations that may be sued under Title VII.

Bergeron v. Henderson · filed 1999-03-30(b), (d)

Specifically, 42 U.S.C. § 2000e(d) defines a “labor organization” as an organization representing “employees” against “employers.” ... Accordingly, the Court holds that labor organizations that represent federal employees against federal employers are excluded from the definition of “labor organizations” that may be sued under 42 U.S.C. § 2000e-2(c).

A union representing federal employees can qualify as a labor organization under Title VII when it deals with a federal agency over employment matters and engages in an industry affecting commerce.

Jones v. American Postal Workers Union, National · filed 1999-09-10(d)

Accordingly, the Defendants constitute labor organizations for purposes of Title VII liability and by proxy the ADA.

Section 2000e(e)(4) requires a local labor organization to be chartered by a qualifying labor organization to satisfy Title VII’s industry-affecting-commerce requirement.

McIntyre v. LONGWOOD CENTRAL SCHOOL DISTRICT · filed 2009-09-30(e)(4)

Thus, even if plaintiff had established a sufficient nexus between MIAA and CAS and/or ESSAA, plaintiff has presented no evidence that CAS or ESSAA are national or international labor organizations, much less ones that also meet the requirements of subsection (1) or (2), such that MIAA may be considered a labor organization for the purposes of Title VII or ADEA.

Section 2000e(e) defines when a labor organization engages in an industry affecting commerce, including through a hiring hall or sufficient membership.

Barneman v. International Longshoreman Association Local 1423 · filed 2020-02-12(e)

For the ADA, the organization must have twenty-five members “during the first year after March 24, 1972” or fifteen or more after that and it must meet other specifications. 42 U.S.C. § 2000e(e). Neither party disputes that the Union, not GSA, operates the hiring hall where the Port Employers hire longshoremen. (Doc. 71-16, p. 2; doc. 69-2, pp. 2–3.) In addition, the record indicates that only the Port Employers were members of GSA which places it below either Act’s membership threshold. (Doc. 17, p. 18.) Thus, GSA does not meet the statutory requirements to be considered a labor organization under either the ADA or ADEA.

A welfare fund that does not deal with employers over grievances or labor disputes is not a labor organization under Title VII.

Jimenez v. Laborers' Welfare Fund of the Health and Wefare Department of the Construction and General Laborers' District · filed 2020-10-08(d)

Title VII defines a labor organization as one that is concerned with a union’s special role “of dealing with employers concerning grievances, labor disputes, wages, rates of pay, hours, or other terms of conditions of employment.” 42 U.S.C. § 2000e. There is no indication that the Fund has any such role dealing with employers concerning grievances or labor disputes, and as such the Court declines to treat the Fund as a labor organization.